US Signal Company, L.L.C.’s Privacy Notice

Last updated: January 1, 2023

We value your business, and we know your privacy is important to you. Accordingly, we have implemented this Privacy Notice which describes:

• How we collect and use personal information that you provide to us when you request or purchase service from US Signal Company, L.L.C. (“US Signal”), or interact with our website or Apps;
• What we do with the information collected; and
• How you can exercise your privacy rights.

This Privacy Notice applies only to the information we collect through our website or applications and information collected for your customer account. It does not apply to the content that customers may store on our systems or at our locations (“Customer Content”). US Signal will not disclose, move, access, or use Customer Content except as provided in US Signal’s service agreements or other terms and conditions.

General Collection and Use of Information

US Signal is a company headquartered in the United States that may collect different types of information on its customers and users based on its business relationship with the customer or user of its website and services. Any personal information collected is stored and processed within the United States.

When requesting or purchasing US Signal services or using US Signal’s website, we may ask you to provide personal information. For example, when you create a US Signal portal account, we will ask you for your email address and to create a password. We may also ask for your phone number for purposes such as two-factor verification. If you choose to sign up for one of US Signal's services, we will ask you for billing information. To complete your order, we may ask for financial information to determine credit, physical address to install services or send billing notifications, authorized usernames, email addresses, and phone numbers. When requesting access to a US Signal building or US Signal data center we may collect biometric data for authentication purposes at entry. At times we may ask for other information such as your name or the name of your company.

During your interaction with US Signal, you may choose to provide us with personal information when you email us, chat with us, submit a form, answer a survey, or communicate with us through social media services like Twitter, LinkedIn, or Facebook.

If you refer an associate to US Signal, we will ask you for their email address. US Signal will then contact your referred associate to determine whether your associate consents to us contacting them.

US Signal allows you to upload your files to our cloud services. While the content of your files may include personally identifiable information, both in the content of a file and in metadata, this Privacy Notice, as stated at the outset, only applies to the information collected related to your account and not to the content that you store on our system.

When you use the US Signal website, we may collect certain information automatically from and about your device. This information may include data about your software, the operating system you use when accessing our service, your Internet Protocol address, and the date and time of each request you make to US Signal. Collecting this information enables us to better diagnose problems with our products, provide customer support more effectively, ensure the security of your data, and ensure the continuous functionality of our products.

We may receive or collect additional information about you from third parties, including event sponsors and web tools. This is primarily to assist us in understanding how we can maintain and improve the services we offer to best serve you. Third-party tools that we use for this are from:

• Google Analytics helps us gather statistical information about the visitors to our website and how they use the website on an anonymous, aggregate basis. We may use this information to gain a better understanding of the users of our website, to improve our website, and to improve our services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics uses. To understand how Google Analytics collects and processes data, please visit <a href="http://www.google.com/policies/privacy/partners/.
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• SurveyMonkey, which US Signal uses to distribute surveys for users to voluntarily complete, will collect the user's IP address.

US Signal may use the information we collect through our products, orders, and Customer contacts for a number of reasons, including to:

• Provide, operate, optimize, and maintain our online platforms, products and services;
• Understand how you use our products and customize your experience;
• Set up online accounts;
• Process, fulfill, and address customer needs when purchasing and using our products and services;
• Send you marketing communications we think you'll find valuable, where it is in accordance with your preferences;
• Provide customer support via online chat services;
• Address your online inquiries and requests sent by email or through the US Signal portal or website;
• Communicate with customers regarding service updates and offers, and provide you with information and access to resources or services that you have requested from us;
• Improve the layout, navigation, and content of our online products;
• Identify and address any server problems or other IT, security, or network issues;
• Investigate, prevent, or take action against any violation of the US Signal Acceptable Use Policy;
• Prevent abuse of the products and services we offer; and
• Carry out other legitimate business purposes, such as to improve our products and services, as well as other lawful purposes about which we will notify our users and customers.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate business interests, we will make clear to you at the relevant time what those legitimate business interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the 'How to contact us' heading below.

Cookies and Other Tracking Technology

Cookies are small data files placed on your computer or mobile device when you visit a website. Cookies are used on the US Signal website to track visitors and visitor activity. Setting cookies on your browser allows our systems to recognize your device using a unique identifier; personal information is not collected. Visitors to the US Signal website from the European Union will be presented with the option to opt-in to the use of cookies and tracking while on our website; cookies will not be utilized if the user does not opt-in. The message will appear on the first visit and the preferences will be recorded for future visits.

We may use several different kinds of cookies on this website including strictly necessary cookies, which are cookies that are necessary for the website to function and cannot be switched off in our systems. We may also use performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our website. In addition to our own cookies, we collaborate with various third-party service providers who also use cookies to help us optimize our website and understand more about the visitors to our website.

Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our website. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and <a href="http://www.youronlinechoices.com.

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Some Internet browsers also may be configured to send “Do Not Track” signals to the online services you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.&nb...;

Communication and Your Choices

From time to time, US Signal will communicate with you via email. There are two types of email you may receive:

1. Service Emails: These are service-related emails such as confirmation of password change, expiration of credit card, or a reply to a support issue. You cannot opt-out of receiving these messages as they are part of the service which US Signal provides to you. You can manage certain service emails by signing into your account. To stop receiving all service emails, you must cancel the service and uninstall the US Signal software from your devices.

2. Marketing Emails: These will include US Signal news, resources, service promotions, and similar types of material. Upon creating a US Signal account, you will be able to manage your email preferences, including opting out of receiving all marketing emails. You will also be able to unsubscribe at any time by using the unsubscribe link provided in any given email.

You are not required to provide all personal information identified in this Privacy Notice to use our website or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.

Information Sharing

Under no circumstances do we rent, sell, trade, or share your physical address, e-mail addresses, or Sensitive Personal Data with any other company for their marketing purposes.

We limit the use of your sensitive personal information and any personally identifiable information to what is necessary to provide services to you. We may share and disclose your personally identifiable information only in the limited circumstances described below:

Information may be shared with vendors and other third-party service providers who require access to your personal information to assist in providing and improving our products. The third parties that access and use your information only on our behalf include companies such as Stripe, Google Analytics, WebFX, Facebook, Twitter, YouTube, LinkedIn, Instagram, Campaign Monitor, SurveyMonkey, Zoom, Microsoft Office 365, Eventbrite, Zerto, Veeam, Acronis, Cloudflare, LiveChat, SalesLoft, Pardot, and Salesforce. For example, we use Salesforce for Help Desk functions and service/trouble ticketing; Microsoft Office 365 is used for internal communication between employees. Pardot enables us to send you marketing emails, subject to your preferences. Salesforce is used for customer relationship management and opportunity tracking. We use Zoom and Microsoft Office 365 to host meetings and Eventbrite to schedule and promote events.

• We may also disclose your information to third parties: (a) where required by law or regulatory requirement, court order or other judicial authorization; (b) in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements; (c) in connection with the sale, transfer, merger, bankruptcy, restructuring, or other reorganization of a business; (d) to protect or defend our rights, interests or property, or that of third parties; (e) to investigate any wrongdoing in connection with our products and services; and (f) to protect the vital interests of an individual.

• To any other person with your consent.
• If you use our services as part of a business, group, or organization where US Signal was set up by an administrator, the administrator may be able to access and control your account. Refer to your organization's internal policies for more information.
• Users can give third parties the ability to access information and content in their account (e.g., through APIs). When other services access and use your information, their conduct is governed by their own terms and policies.
• We may disclose aggregate, non-identifying information about how US Signal products and services are utilized.

Information not subject to this Privacy Notice

1. This Privacy Notice does not apply to Customer Content. Please see our service terms and conditions for more information about how we handle your Customer Content.

2. If you participate in public forums of any kind, including but not limited to social networking sites, social media, blogs, chat rooms, or forums, even if US Signal participates in these sites, you are advised the information submitted to these sites is considered public. Any information considered public may be read, collected, distributed, or used by others without your consent. Use of the sites referenced herein is at your sole discretion. Information shared on these sites is not covered by this Notice.

3. Our website contains links to third-party websites and third-party plugins (such as social media sharing buttons) operated by other companies. We are not responsible for the privacy practices of such other websites. We encourage you to read the Privacy Policy/Notices of such other websites which you visit. This Privacy Notice applies solely to information collected for the use of US Signal's products and services.

Information Retention and Deletion

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for legal, tax, or regulatory reasons, or other lawful purposes.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Privacy of Children

1. The US Signal website is not designed nor intended for children under the age of 18. US Signal does not knowingly collect any information from children under the age of 18.

2. The US Signal website, applications, and services are designed specifically for individuals the age of 18 and over.

Customer Proprietary Network Information (“CPNI”)

CPNI is information that is available to US Signal due to its business relationship with a customer. This information includes quantity, location, type of service ordered, amount of service used, and billing information related to the service. Customer’s name, address, and telephone number are not considered to be CPNI. US Signal does not disclose CPNI to any third party without written permission by the customer of record.

Personal Information Security

The security of your personal information is very important to us.

We use appropriate technical and organizational security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, both during transmission and after receiving. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Treatment of Biometric Data

Biometric data is physical human characteristic information such as a fingerprint, iris scan, handprint, facial shape, finger scan, and other similar techniques used to allow or confirm unique individual identification. For purposes of this Notice, biometric data includes biometric identifiers and biometric information as defined under federal, state, or local legislation and ordinances such as the Illinois Biometric Information Privacy Act.

In the course of business, US Signal may use biometric data to perform background checks or use biometric data as the access key to secured areas such as US Signal data centers. US Signal will inform individuals as to the intended use of the biometric data prior to collection. Where required by law, US Signal will obtain written consent prior to the collection of the biometric data. Biometric data collected will be used exclusively for the intended purpose and will not be disclosed without the individual’s written consent unless required by law or a court-ordered warrant or subpoena.

Biometric data collected by US Signal will be processed, stored, and protected using the same standard of care and security controls used to process, store, and protect other restricted or private data it has in its possession. Once captured, iris scans and other biometric data will be encrypted and securely stored on US Signal’s systems.

Unless otherwise outlined in the consent for biometric data collection signed by the individual, biometric data will be destroyed following notification regarding the individual’s discontinued need for access to the building or access to the sensitive data for which the biometric data was collected. In the case of a US Signal employee, biometric data will be destroyed upon termination of employment. Destruction of the biometric data will occur within the timeframe required by law.

International Data Transfers

Any information you provide to us that is covered by this Privacy Notice may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Notice regardless of where your personal information is kept. Regarding transfers from the European Economic Area ("EEA") to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. In addition, US Signal complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as described below. If you reside in other non-U.S. jurisdictions outside the EEA, your use of our website or services or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.

Privacy Policy Relating to EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (Applicable to data subjects within the European Union)

US Signal complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. US Signal has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. If there is any conflict between the policies in this US Signal Privacy Shield Policy (“Privacy Shield Policy”) and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/...;

Please note that for EU data protection legislation purposes, US Signal is the processor of your personal information. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, US Signal is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. US Signal complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

In compliance with the Privacy Shield Principles, US Signal commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact US Signal at:

US Signal Company
Attn: Data Protection Officer
201 Ionia, SW
Grand Rapids, MI 49503
[email protected]
616.233.5701 | 866-274-4625

US Signal has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) regarding unresolved Privacy Shield complaints concerning non-human resources and human resources data transferred from the EU and Switzerland including in the context of the employment relationship.

Data Protection Rights

Depending on where you live, you may have one or more of the following rights:

• If you wish to access your personal information that US Signal collects, you can do so at any time by contacting us using the contact details provided under 'How to contact us' heading below.
• You can correct, update, or request deletion of your details in your account by logging in to your account. You can also contact us using the contact details provided under 'How to contact us' heading below in order to request that your data is deleted.
• If you are located in the EEA, you can object to the processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information where it is technically possible. Again, you can exercise these rights by contacting us using the contact details below.
• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to file a complaint with the data protection authority about our collection and use of your personal information. (Contact details for your data protection authority, if any, are available at https://ec.europa.eu/justice/a....)
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you. Alternatively, please contact us at [email protected]. Please include your complete name and email address. Note that it may take up to 30 business days to remove you from our marketing lists and, after this point you will still receive service emails from us.
• You may have the option, under certain conditions, to invoke binding arbitration.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Data Integrity and Purpose Limitation

US Signal limits the collection of personal data covered by this Privacy Notice to information relevant for processing purposes. US Signal does not process such personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the covered individual.

US Signal takes reasonable steps to ensure that such personal data is: reliable for its intended use, accurate, complete, and current. US Signal takes reasonable and appropriate measures to comply with requirements under applicable laws and compliance frameworks to retain personal data in identifiable form only for as long as it serves a purpose of processing.

Complaints / Dispute Resolution

You can direct any questions or complaints about the use or disclosure of your personal information to us at [email protected]. We will investigate and resolve any complaints or disputes regarding the use of personal information within forty-five (45) days of receiving your complaint.

Privacy Notice Updates

Updates to this Privacy Notice will be made when required in response to changing legal, technical, or business developments. The Privacy Notice is subject to change without notice. US Signal encourages its customers and users to check its website periodically for any changes or revisions to this Privacy Notice. When we update our Privacy Notice, we will take appropriate measures to inform you when required by law. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

How to Contact Us

If you have any questions or concerns regarding the use or disclosure of your personal information, you can contact us by sending an email to [email protected] or by contacting us at:

US Signal Company
Attn: Data Protection Officer
201 Ionia, SW
Grand Rapids, MI 49503
616.233.5701 | 866-274-4625